A new “tax ruling” system will apply in Italy at the start of 2016. The new system reflects changes made by Legislative Decree no. 156. In general, a taxpayer requests a tax ruling from the tax authorities as to the tax treatment of a transaction or an interpretation of the tax laws.
The new system includes new classifications for tax rulings:
The new system also revises the timing for a taxpayer to file a tax ruling application and the time period for the tax authorities to respond. The new tax ruling system further provides rules for when a request for a tax ruling is mandatory and when a tax ruling is option. For instance, a taxpayer must request a tax ruling in certain situations when anti-avoidance measures would be involved, but a tax ruling is no longer mandatory in situations concerning safe-harbour conditions and the controlled foreign corporation (CFC) rules.
Read an October 2015 report [PDF 283 KB] prepared by the KPMG member firm in Italy: New tax ruling system for Italy
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